Traduction de «entreprise exploitée activement » (Français → Anglais) :

active business

active business

active business income [ ABI | active income ]

R&D personnel % as of labour force,business enterprises | R&D personnel as % of labor force,business enterprises

16. Notwithstanding the provisions of paragraph 6 of Article X and of paragraph 15 of this Protocol, where a resident of Canada controls, directly or indirectly, alone or together with members of a related group or together with not more than four other residents of Canada, a company which is a resident of Brazil and in which he holds an equity percentage of at least 10 per cent, such resident may be subject to tax in Canada on his proportionate share of the aggregate of the company’s net income for any taxation year from property and businesses other than active businesses and the company’s net taxable capital gains for any taxation yea ...[+++]r from the alienation of property other than property used for active business purposes; for the purposes of this provision, any income from a source in a country other than Canada which pertains to or is incident to an active business carried on in a country other than Canada shall be deemed to be income from an active business.

(9) A disposition of a common share of an active business corporation (in this subsection referred to as the “subject share”) by an individual that, but for this subsection, would be a qualifying disposition of the individual is deemed not to be a qualifying disposition of the individual unless the active business of the corporation referred to in paragraph (a) of the definition “active business corporation” in subsection (1) was carried on primarily in Canada

4. Dividends received by a company which is a resident of Canada from a company which is a resident of Brazil shall be exempt from tax in Canada if the company receiving the dividends holds an equity percentage of at least 10 per cent in the company paying the dividends and if the profits out of which the dividends are paid are derived from carrying on an active business in Brazil or in a country with which Canada has concluded a double taxation convention; for the purposes of this provision, any income from sources in a country other than Canada which pertains to or is incident to an active business carried on in a country other than C ...[+++]anada, shall be deemed to be profits derived from carrying on an active business.

(x) the loss from an active business, from a non-qualifying business or from property (as the case may be) of a foreign affiliate of a taxpayer resident in Canada for a taxation year is the amount of that loss, if any, that is computed by applying the provisions in this subdivision with respect to the computation of income from the active business, from the non-qualifying business or from property (as the case may be) of the foreign affiliate for the taxation year with any modifications that the circumstances require;